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But next year
the 5 April concession will be gone and the final FPS together with the P35 like questions will have to be submitted on or before the last payment. This could be the first half of March for some firms in which case they will have to know the answers to the following well before the end of the tax year:
Any 'Free of tax' payments made to an employee.Did anyone else pay any expenses or benefits to any of your employees while they were employed by you during the year.Anyone employed by a person or company outside the UK working for you in the UK for 30 days or more in a row.Any of an employee’s pay you've paid to someone other than the employee, such as to a school.If you need to complete forms P11D and P11D(b) for the tax year.If you're a service company (if the company is a Service Company and operates the intermediaries legislation, known as IR35 or Managed Service Companies legislation).
Most of the questions can be answered fairly easily prior to the tax year end but one requires enquiry of 3rd parties and the P11D question can't possibly be answered with any degree of certainty until the tax year has ended on the 5 April - too late for the submission!
Does anyone have any idea of how to square this circle - or am I missing something?
Use the EPS
Hi, you aren't missing anything but it is also possible to do want you want.
The only rule HMRC have defined here is that the end of year declarations must be included in the last submission of the year, and this could be either a FPS or an EPS, they do not have to be sent by the time the last payment is made.
While a FPS will have to be sent by the 5th April (because this is the last day in the year in which you could pay somebody, therefore the last day on which you can adhere to the 'on or before' rule) you have until the 19th April before you have to send the EPS.
The last EPS you send does not have to be for an adjustment or a nil payment, it can just include the declarations if you want, so regardless of the situation, you can adhere to all of the RTI rules and wait until the 19th April before sending the declarations.
Whether or not you are able to do this will be down to the software that you use and how the different RTI submission types have been implemented.
This is how we have designed the end of year process within our RTI software.
Gary
Sage UK